ML14063A628

Annual Assessment Letter for Wolf Creek Generating Station (Report 05000482/2013001)

ML14063A628
Person / Time
Site:	Wolf Creek
Issue date:	03/04/2014
From:	Dapas M Region 4 Administrator
To:	Heflin A Wolf Creek
O'Keefe N
References
IR-13-001
Download: ML14063A628 (6)

See also: IR 05000482/2013001

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

March 4, 2014

Mr. Adam C. Heflin, President

and Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

SUBJECT: ANNUAL ASSESSMENT LETTER FOR WOLF CREEK GENERATING

STATION (REPORT 05000482/2013001)

Dear Mr. Heflin:

On February 12, 2014, the NRC completed its end-of-cycle performance review of Wolf Creek

Generating Station. The NRC reviewed the most recent quarterly performance indicators (PIs)

in addition to inspection results and enforcement actions from January 1, 2013, through

December 31, 2013. This letter informs you of the NRCs assessment of Wolf Creek

Generating Station during this period and its plans for future inspections at that facility.

The NRC determined that overall, Wolf Creek Generating Station was operated in a manner that

preserved public health and safety and met all cornerstone objectives. The NRC determined

the performance at Wolf Creek Generating Station during the most recent quarter was within the

Licensee Response Column of the NRCs Reactor Oversight Process (ROP) Action Matrix

because all inspection findings had very low (i.e., Green) safety significance, and all PIs

indicated that plant performance was within the nominal, expected range (i.e., Green).

Therefore, the NRC plans to conduct ROP baseline inspections at your facility.

Although plant performance was within the Licensee Response Column, the NRC has not yet

finalized the significance of a preliminary Greater-than-Green finding in the physical security

cornerstone documented in NRC Inspection Report 05000482/2013403 (ML13346A227). The

final safety significance determination may affect the NRCs assessment of plant performance

and the enclosed inspection plan. You will be notified by separate correspondence of the final

significance for this finding, as well as any changes to our performance assessment and

associated inspection plan.

At the beginning of this assessment cycle, Wolf Creek Generating Station was in the Degraded

Cornerstone Column because there was one Yellow finding and one White performance

indicator in the Mitigating Systems Cornerstone. The Yellow finding involved your staffs failure

to provide adequate oversight of contractors while they performed work that could affect safety-

related equipment in April 2011. The performance indicator for Mitigating Systems Performance

Index - Emergency AC System (MSPI - EAC) had been reported as White since the first

quarter of 2012. On June 7, 2013, the NRC completed a supplemental inspection pursuant to

Inspection Procedure 95002, "Supplemental Inspection for One Degraded Cornerstone or Any

Three White Inputs in a Strategic Performance Area," at Wolf Creek Generating Station. This

A.Heflin -2-

inspection was performed to assess your staffs evaluation of the root causes, contributing

causes, and corrective actions associated with the Yellow finding, and included an assessment

of actions to address four open substantive cross-cutting issues. The team also performed a

limited scope independent safety culture assessment follow-up in accordance with Inspection

Procedure 40100, Independent Safety Culture Assessment Follow-up. The inspectors

determined that your staff performed a comprehensive evaluation to identify appropriate causes

for the Yellow finding, and corrective actions were appropriate to address those causes. Based

on the results of this inspection, the Yellow finding was closed in NRC Inspection Report 05000482/2013010 (ML13203A329).

On April 29, 2013, the NRC completed the supplemental inspection to review the action taken to

address the White MSPI - EAC, pursuant to Inspection Procedure 95001, Supplemental

Inspection for One or Two White Inputs in a Strategic Performance Area. As documented in

NRC Inspection Report 05000482/2013009 (ML13126A197), this inspection was performed to

assess your staffs evaluation of the root causes, contributing causes, and corrective actions

associated with the White PI. The PI data reported for Wolf Creek Generating Station for the

second quarter of 2013 indicated that MSPI - EAC had returned to Green. Therefore, since

four quarters had passed since the White PI was identified; the NRC had concluded based on

the 95001 supplemental inspection results, that you had adequately evaluated and addressed

the performance issues; and given that the PI had returned to Green as of June 30, 2013, Wolf

Creek Generating Station was returned to the Licensee Response column as of July 1, 2013.

The NRC also issued a Chilling Effect Letter (CEL) (ADAMS ML13233A208) to Wolf Creek

Nuclear Operating Corporation on August 19, 2013. The CEL was issued because the

Occupational Safety and Health Administration (OSHA) had issued a finding of discrimination

for raising safety concerns against a former employee of an engineering contractor employed by

Wolf Creek Nuclear Operating Corporation, and due to the NRC identifying that a chilled work

environment existed within your facilitys Quality Assurance Group. Issuance of a CEL meets

the NRC criteria in Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment

Program, for the identification of a cross-cutting theme in the area of safety conscious work

environment (SCWE). However, the NRC has assessed your 30-day and 6-month responses to

the CEL, and conducted a public meeting in the Region IV office on January 22, 2014, to

discuss the actions that you are taking to address the working environment at your facility. The

NRC has decided not to open a substantive cross-cutting issue in the area of SCWE at this time

because the NRC staff does not have a concern with your actions. This theme will continue to

be reviewed during the next two performance assessments as we continue to monitor your

staffs actions to ensure Wolf Creek Generating Station is a workplace that fosters an

environment where employees feel free, and are encouraged, to raise safety concerns.

The enclosed inspection plan lists the inspections scheduled through June 30, 2015. Routine

inspections performed by resident inspectors are not included in the inspection plan. The

inspections scheduled to be conducted during the last nine months are tentative and may be

revised based on the results of the mid-cycle performance review. The NRC provides the

inspection plan to allow for the resolution of any scheduling conflicts and personnel availability

issues. The NRC will contact your staff as soon as possible to discuss changes to the

inspection plan should circumstances warrant any changes. This inspection plan does not

include security related inspections, which will be sent via separate, non-publicly available

correspondence.

A.Heflin -3-

An NRC audit of licensee efforts towards compliance with Order EA-12-049, Order Modifying

Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis

External Events, is ongoing. This audit includes an onsite component in order for the NRC to

evaluate mitigating strategies as described in licensee submittals, and to receive and review

information relative to associated open items. This onsite activity will aid the NRC staff in

development of an ultimate Safety Evaluation for the site. The NRC staff will be working with

your staff to establish a date for the onsite component audit. A site-specific audit plan for the

visit will be provided in advance to allow sufficient time for preparations.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of

cross-cutting aspects were revised effective January 1, 2014. New cross-cutting aspects will be

coded in accordance with the latest revision to NRC Inspection Manual Chapter (IMC) 0310,

Aspects within Cross-Cutting Areas, dated December 19, 2013. Cross-cutting aspects

identified in the last six months of 2013 using the previous terminology will be converted to the

revised language in accordance with the cross-reference in IMC 0310. The revised cross-

cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-

cutting issues in accordance with IMC 0305 starting with the calendar year 2014 mid-cycle

assessment.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be

available electronically for public inspection in the NRC Public Document Room or from the

Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS

is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Please contact Neil OKeefe at 817-200-1141 with any questions you or your staff may have

regarding this letter.

Sincerely,

/RA/

Marc L. Dapas,

Regional Administrator

Docket No. 50-482

License No. NPF-42

Enclosure:

Inspection Plan

A.Heflin -4-

R:\_REACTORS\EOC 2013\WC2013 EOC LTR NFO 140304.docx ML14063A628

ADAMS: No Yes SUNSI Review Complete Reviewer Initials: NFO

Publicly Available Non-Sensitive

Non-publicly Available Sensitive

DRP B/BC DRS/DIR DRP/DIR RA

NOKeefe JClark KKennedy MDapas

/RA/ /RA/ /RA/ /RA/

02/26/2014 02/28/2014 02/28/2014 03/03/2014

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Page 1 of 2 WolfCreek

02/27/2014 13:10:28 Inspection I Activity Plan

Report22

03/01/2014 - 06/30/2015

Title

RS 12 PI - RADIATION SAFETY 2

03/17/2014 03/21/2014 IP 71124.01 RadiologicalHazard Assessment and Exposure Controls

03/17/2014 03/21/2014 IP 71124.02 Occupational ALARA Planning and Controls

03/17/2014 03/21/2014 IP 71151-0R01 Occupational Exposure Control Effectiveness

03/17/2014 03/21/2014 IP 71151-PR01 RETS/ODCM Radiological Effluent

TSB 52B - BIENNIAL PI&R 4

05/19/2014 05/23/2014 IP 71152B Problem Identification and Resolution

06/02/2014 06/06/2014 IP 711528 Problem Identification and Resolution

RS 5678 - RADIATION SAFETY- TEAM 4

06/02/2014 06/06/2014 IP '11124.05 Radiation Monitoring Instrumentation

06/02/2014 06/06/2014 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment

06/02/2014 06/06/2014 IP 71124.0'1 Radiological Environmental Monitoring Program

06/02/2014 06/06/2014 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

INSP - BIENNIAL REQUAL INSPECTION 3

08/25/2014 08/29/2014 IP 7111111B Licensed Operator Requalification Program

EB2-05T - TRIENNIAL FIRE PROTECTION INSPECTION 4

10/20/2014 10/24/2014 IP 7111105T Fire Protection [Triennial]

11/03/2014 11/07/2014 IP 7111105T Fire Protection [Triennial]

EP-1 - EP PERFORMANCE INDICATORS

11/17/2014 11/21/2014 IP 71151-EP01 Drill/Exercise Performance

11/1712014 11/21/2014 IP 71151-EP02 ERO Drill Participation

11/17/2014 11/21/2014 IP 71151-EP03 Alert & Notification System

EP-2 - EP PROGRAM INSPECTION

11/17/2014 11121/2014 IP 7111402 Alert and Notification System Testing

11/1712014 11/21/2014 IP 7111403 Emergency Preparedness Organization Staffing and Augmentation System

11/17/2014 11/2112014 IP 7111404 Emergency Action Level and Emergency Plan Changes

11/17/2014 11121/2014 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies

71111.08 - INSERVICE INSPECTION

02/23/2015 03/06/2015 IP 7111108P lnservice Inspection Activities - PWR

RS 13 PI - RADIATION SAFETY 2

03/09/2015 03/13/2015 IP 71124.01 Radiological Hazard Assessment and Exposure Controls

03/09/2015 03/13/2015 IP '11124.03 In-Plant Airborne Radioactivity Control and Mitigation

03/09/2015 03/13/2015 IP '11151-0R01 Occupational Exposure Control Effectiveness

rfhis report does not include INPO and OUTAGE adlvffles.

This report shows only on-site and announced inspection procedures.

Enclosure

Page 2 of 2 WolfCreek

02/27/2014 13:10:28 Inspection I Activity Plan

Report22

03/01/2014 - 06/30/2015

i Unit Planned Dates No. of Staff

i Number

- --*L.

Start End Title on Site

RS 13 PI -RADIATION SAFETY 2

03/09/2015 03/13/2015 IP 71151-PR01 RETS/ODCM Radiological Effluent

EB1-17T - WC PERMANENT PLANT MODS & 50.59

06/15/2015 06/26/2015 IP 7111117T Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

Ttiis report does not inClude INPO and OUTAGE activities.

• This report shows only on-site and announced inspection procedures.

Enclosure